Two Audit Case Studies Reveal the Cost of Incomplete Corrective Actions

A session hosted by Karyn M. Campbell, Senior Director, QA Audit and Compliance, AbbVie, at the PDA/FDA Joint Regulatory Conference 2026, walked attendees through the full lifecycle of a GMP audit finding, from the moment an auditor flags a concern in a daily wrap-up to the effectiveness check that ultimately closes it.¹ The presentation used a running example, an incomplete batch reconciliation record, to illustrate how a single observation moves through containment, root cause analysis, risk assessment, CAPA design, implementation, and verification.

Why Does Root Cause Analysis Determine Everything Downstream?

The session's central argument was that a CAPA is only as strong as the root cause investigation behind it.¹ Campbell pointed to tools like 5 Whys, fishbone diagrams, and fault tree analysis as ways to separate symptoms from true causes. Regulators expect companies to engineer out human error through procedural or technical controls rather than close investigations at operator error. The session extended that idea into risk-based prioritization, urging quality teams to confirm that an investigation's scope, or bracket, is accurate before resources are committed to a response.

When Does a Local Fix Become an Above-Site Problem?

The session spoke on a decision framework for scoping impact: does a finding touch a shared system (HVAC, water, LIMS), a common product or supplier, or a repeated trend across sites?¹ Using a batch reconciliation case study, Campbell showed how a defect in one batch can trigger an expanded assessment if it shares a packaging material with other batches, versus staying a local, isolated fix. The framework tied directly into a governance escalation pathway running from site quality management up through regional leadership, a corporate quality council, and, for strategic decisions, the global head of quality. The session framed above-site assessment as a way to avoid isolated local fixes that leave systemic risk undetected elsewhere in a network, a concern that echoes broader industry discussion of enterprise quality accountability.

What Separates a Response That Holds Up?

Campbell broke down what regulators want to see in writing: concise, factual, evidence-based responses that explicitly link the observation to its root cause and to the corrective actions taken.¹ Vague commitments and unsupported statements were called out as red flags. Companies should follow up with evidence of completed actions and verified effectiveness even after submitting a response, rather than assuming silence from the agency means acceptance.

What Did the Case Studies Teach?

Two case studies drove the stakes home.¹ In the first, a company's corrective action for an out-of-calibration scale stalled because the proposed method changes conflicted with a regulatory filing, and the unresolved issue resurfaced as a repeat observation at the next audit. In the second, a contract manufacturer declined to redo airflow visualization studies after deficiencies were flagged in a mock pre-approval inspection, only for FDA to later request the original videos and issue a formal observation on the same deficiencies. Both cases underscored the presentation's closing message: unresolved findings don't disappear, they escalate.

References

Parenteral Drug Association. PDA/FDA Join Regulatory Confernce 2026 Agenda. Available at https://www.pda.org/global-event-calendar/event-detail/pda-fda-joint-regulatory-conference-2026#agenda. Accessed Sept 16, 2026.